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10 years of continuous hospital at home funding on the line in congressional waiver extension

Week of September 7 - September 13, 2025
7 minutes
The Buzz This Week 

Congress has returned from the August recess and is focused on the highly anticipated appropriations bill, with a looming September 30 deadline. The Acute Hospital Care at Home (or simply “hospital at home”) waiver program is also set to expire on September 30. Numerous healthcare organizations have urged Congress to extend the waivers either through appropriations or another bill, like the most recently introduced Telehealth Modernization Act. Such an extension would maintain Medicare reimbursement for home-based acute care for another 5 years.  

The hospital at home program allows hospitals to provide hospital-level care to certain patients in their homes, even though doing so would normally violate a condition of participation in Medicare and Medicaid that requires 24/7 availability of in-person nursing care.  

As of August 2025, 413 hospitals across 146 health systems and 39 states had been approved to provide hospital at home services to patients. But with the September 30 expiration approaching, health systems will need to prepare themselves for all possible outcomes.

Hospital at home has broad support from providers, patients, and caregivers. They contend lawmakers should back the proposed 5-year waiver extension, as the model has demonstrated improved patient outcomes, reduced healthcare costs, and strengthened access to care for older Americans.

Congress has already extended hospital at home waivers multiple times since the program began in November 2020, during the height of the COVID-19 pandemic. Congress extended the program in 2022 for 2 years, again at the end of 2024 for 90 days, and in March 2025 as a stopgap measure until September 30, 2025.  

The Telehealth Modernization Act, a bipartisan bill introduced in the House and Senate, aims to extend the hospital at home waiver for 5 years through the end of 2030 and directs the Centers for Medicare & Medicaid Services (CMS) to conduct a new study of the program. to conduct a new study of the program.

The study provision included in the bill would require the US Department of Health and Human Services (HHS) and CMS to conduct a comprehensive study comparing home-based care and inpatient care across several criteria, including care quality, infection rates, hospital readmissions, and patient and caregiver satisfaction. 

Why It Matters

While the hospital at home waiver has broad support, the uncertain political environment means hospitals and health systems need to prepare now for a range of scenarios:

  • Scenario 1. The hospital at home waiver is extended, but the health system has not yet started a hospital at home program

  • Scenario 2. The hospital at home waiver is extended, and the health system has an existing program

  • Scenario 3. Hospital at home waivers are not extended or the vote is delayed after September 30  

Scenario 1. The hospital at home waiver is extended, but the health system has not yet started a hospital at home program

The waiver represents a rare strategic inflection point to secure both immediate relief for capacity constraints and long-term positioning in a consumer-centric, value-based marketplace. With payment parity locked for the next 5 years, speed to scale will substantively drive ROI. To best capitalize on the opportunity, health systems looking to develop programs should focus on the following:  

  • Secure leadership alignment, commitment, and visible endorsement. Early agreement on the mission, goals, success factors, and investment requirements will help overcome predictable barriers such as cultural resistance, resource allocation, and concerns over economic viability.
  • Build a robust business case and pro forma. The most common mistake when launching a program is under-resourcing and under-investing. This leads to an inefficient, subscale program that’s incapable of growth. A clear business case will quantify risks and benefits through scenario modeling across key variables. It will ensure stakeholders align on the program’s financial, strategic, and time-to-value impact.
  • Prioritize patient populations and sites for launch. Identify high-impact, clinically appropriate patient populations, and select initial hospitals at which hospital at home can demonstrate value quickly. This will build credibility, momentum, and expertise before scaling to a broader enterprise rollout.
  • Design the scalable operating model. Define the clinical, operational, and technical requirements needed to deliver safe and effective acute care at home, including insource and outsource decisions for key functions. This is not a minimum viable product (MVP) but the permanent, scalable, high-quality operating model.
  • Plan for scale and integration into a broader care at home strategy. Position hospital at home as the foundation of a broader care at home ecosystem. Once lanched, a real program will create a 24/7 clinical command center, 24/7 remote patient monitoring (RPM) automation and alerts, and 24/7 distributed care capabilities. All of these will be essential to the future healthcare delivery context. Ensure alignment with the overall enterprise strategy by incorporating change management, performance metrics, and communication strategies from the outset.

Scenario 2. The hospital at home waiver is extended, and the health system has an existing program

The waiver extension provides stability and allows health system leaders to invest in scaling hospital at home as a core strategic asset. Success will require substantive investment in dedicated teams, data-driven patient identification, robust financial analytics, and a robust technical and operating infrastructure to support growth. It will also require a persistent focus on continuous improvement and cultural change management, such as engaging providers, patients, and caregivers to build trust in the model.  

To grow efficiently and strategically, health systems should:

  • Reaffirm the strategy and business case for scale. Develop a multi-year hospital at home financial model that accounts for reimbursement pathways, backfill opportunities, and unit economics. A clear, operating “virtual P&L” linked to the annual budget process will strengthen executive alignment and ensure hospital at home is viewed appropriately as a core and enduring clinical service offering.
  • Redesign the care team and operating model for growth. Transition to a dedicated hospital at home care team with clear roles, scalable staffing models, and streamlined workflows to ensure readiness to safely grow from single-digit average daily census (ADC) to a “minimum viable” census of ~15 patients and beyond.
  • Optimize patient identification and enrollment. Develop a multi-pronged “push” and “pull” patient identification and acquisition program. Such a program leverages emerging AI patient-identification tools, electronic health record (EHR)-based provider prompting and alerts, and formalized navigator roles to capture more eligible patients and overcome workflow breakdowns and any provider hesitancy.
  • Invest in patient, caregiver, and clinician engagement. Build provider and patient confidence in hospital at home through standardized education, clear communication, and structured change management to boost referrals and enrollment.
  • Build performance management and continuous improvement discipline. Set and track key performance indicators (KPIs) across clinical, operational, financial, and experience domains with automated reporting. Use iterative improvements to remove barriers and sustain hospital at home growth without compromising quality or experience.

Scenario 3. Hospital at home waivers are not extended or the vote is delayed after September 30  

Health systems can prepare their hospital at home programs using the following measures:

  • Evaluate the economics of their hospital at home care model for different scenarios. Even without the waiver and the associated reimbursement, hospital at home can still be financially viable. Leaders need to understand their program’s operating cost vs. the cost in brick and mortar. They also need to analytically assess whether a different care at home deployment model may be more appropriate, such as an advanced “early discharge” program.
  • Lock in near-term commercial and Medicare Advantage payer paths, and consider the ramifications of gating enrollment by payer. Prioritize delays with commercial payers for hospital at home-equivalent rates or bundles. Draft “reversion” terms that convert hospital at home episodes to alternative covered sites of care if Medicare lapses.
  • Stand up a 30-day contingency plan with clear scale, timing, eligibility, and services levers. Freeze non-critical expansion, pre-model ADC and budget scenarios, and define trigger points for narrowing inclusion criteria if reimbursement lapses. Use hospital at home value drivers to decide what to keep running if payments stop.  
  • Prepare an operational contingency playbook. Map active hospital at home workflows to compliant alternatives, unwind waiver-dependent flexibilities, and update billing, IT requirements, consent, and vendor agreements accordingly.
  • Keep clinical quality and safety data front and center to sustain referrals and strengthen their public case. Share outcomes showing lower utilization and readmissions for home-treated acute patients. Reinforce internal governance for patient selection and escalation. And equip clinician champions with evidence to maintain confidence during reimbursement turbulence.
  • Mobilize a rapid advocacy and communications cadence tied to federal action. Brief board members and local officials with concrete capacity and community impacts. Align messaging with hospital at home advocacy groups. And track and communicate status updates to frontline teams.

All signs remain positive for ongoing funding, building on the demonstrated value of the hospital at home waiver. Even so, without congressional action, Medicare reimbursements would discontinue. Hospitals would need to alter their strategies to offset the capacity relief—but not necessary shut down their programs to continue realizing the benefits of this proven care model.  .  

If the waiver passes as expected, leading health systems across the country will finally have the enduring financial certainty they need to press this new site of care further into the mainstream—further transforming how and where care is delivered.

 

RELATED LINKS

American Hospital Association:
Fact Sheet: Extending the Hospital-at-Home Program

Healthcare Leaders:
CFOs Have the Financial Data.

Healthcare IT News:
140 organizations urge Congress to extend the hospital-at-home program

Home Health Care News:
New Bill Would Extend Hospital-At-Home Waiver Through 2030 - Home Health Care News 

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